{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Synthetic replication with swaps, derivatives use, and opaque structure. (ESMA/2015/187)",
        "classification": "complex",
        "supporting_data": "The Invesco Health Care S&P US Select Sector UCITS ETF is classified as complex. The KID states that the fund uses unfunded swaps to achieve its investment objective.  The use of swaps is highlighted within the documentation and the fund uses synthetic replication to track the S&P Select Sector Capped 20% Health Care Index. The ESMA guidance on MiFID II appropriateness (ESMA35-36-1640) highlights the need for firms to distinguish between complex and non-complex products and assess these elements in determining MiFID compliance.  ESMA also states that when a firm assesses the appropriateness of a transaction, it should take account of the clientu2019s knowledge and experience, as well as the complexity of the product. The use of derivatives/swaps is specifically mentioned by ESMA in its guidance as a reason for complexity, and a firm should assess the specific knowledge of the client in determining the appropriateness of this investment."
    }
}